Subject: National Park Service Proposed Rule: Hunting and Trapping in National Preserves in Alaska Regulation Identifier Number (RIN) 1024-AE38

Dear Regional Director Frost:

I am writing to you on behalf of over 1,600 members of the Coalition to Protect America’s National Parks (Coalition), a non-profit organization composed entirely of retired, former, or current employees of the National Park Service (NPS). The Coalition is preparing to submit detailed comments in opposition to the Service’s Proposed Rule (RIN 1024-AE38) regarding Hunting and Trapping in National Preserves in Alaska. We are concerned, however, that the comment period on the Proposed Rule is ending without NPS having analyzed its environmental impacts.

This letter precedes the Coalition’s pending substantive comments on the Proposed Rule in order to request that NPS extend the comment period to coincide with the NEPA process. It is also crucial that NPS prepare an Environmental Impact Statement in light of the anticipated environmental impacts as well as controversial nature of the Proposed Rule, and that the public have a meaningful opportunity to comment on the proposal once this analysis is available.

An Environmental Impact Statement is required based on the Proposed Rule’s impacts to wildlife of the Alaska national preserves, embrace of inhumane and widely-condemned hunting practices, and controversial nature.

In the Proposed Rule, NPS indicates its intent to prepare an Environmental Assessment (EA) to “determine whether [the Rule] will have any significant impacts on wildlife or other resources.” NPS should acknowledge that an Environmental Impact Statement (EIS) is required in light of the Rule’s expected impacts to wildlife of the Alaska units, the impacts on individual animals as a result of inhumane and widely condemned hunting practices, and the controversy surrounding the proposal.

The NPS NEPA Handbook[1] provides that an EIS is the appropriate NEPA approach where, among other reasons, a proposal “is expected to, or has the potential to result in significant adverse environmental impacts” or where “there is a high degree of controversy over the environmental impacts of a proposed action.” NPS NEPA Handbook § 1.5(D). “Controversy” can mean both opposition to the proposal, or where a “substantial dispute exists as to the nature of the environmental consequences of a proposed action.” Id.

The prohibited hunting practices (killing black bears with cubs, using artificial light, at den sites; killing brown bears over bait killing wolves and coyotes and pups during the denning season; killing swimming caribou from a moving motorboat, etc.) that would be reinstated by the Proposed Rule are not only inconsistent with the NPS governing laws, regulations and principles of public stewardship, but also unsportsmanlike and repugnant to the vast majority of hunters. The EIS should consider not only the broader impacts of the Proposed Rule to Alaska units, but also the more pointed impacts of these widely-condemned hunting practices.

While we support subsistence hunting and trapping, the Coalition strongly opposes the handful of specific hunting practices that are currently prohibited in paragraphs (f) and (g) of 36 CFR § 13.42. These practices are inconsistent with NPS mandates and are obviously intended or reasonably likely to manipulate wildlife populations for harvest purposes.

Manipulating predators and prey can alter populations, population dynamics, and often their habitat. There is abundant literature on the importance of large carnivores to naturally functioning ecosystems. There is also abundant literature on the impacts of hunting on naturally functioning populations of wild animals including potential adverse genetic consequences. The potential environmental impacts of this Proposed Rule are significant, as evidenced by disruptions to ecosystems from similar practices in the lower 48 states. Before any modification to the 2015 rule is proposed and adopted, it is essential that the NPS complete a fulsome EIS that examines the impacts to the Alaska units.

The controversy here should come as no surprise to NPS. The weight of sound science and public opinion supports leaving the 2015 rule “as is.” NPS has received over 145,000 comments so far, even before it has released materials seriously considering the environmental impacts of its Proposed Rule. Based on the level of controversy alone, NPS must fully consider these impacts by preparing an EIS.

NPS should extend the comment period on the Proposed Rule to coincide with the release of the NEPA document.

The comment period on the Proposed Rule should be extended further to coincide with the release of the draft NEPA document. This is consistent with NPS NEPA process, which, following CEQ regulations, directs the agency to “integrate the NEPA process with other planning at the earliest possible time to ensure that planning and decisions reflect environmental values.” NPS NEPA Handbook § 1.4(A).

For a decision with significant potential environmental impacts, “[t]he NEPA process should begin when the NPS has a goal for which it is actively preparing to make a decision and has developed a proposal to the point where its environmental impacts can be meaningfully analyzed.” NPS NEPA Handbook § 1.4(B). NPS has no excuse at this stage for avoiding a meaningful analysis of the environmental impacts of rescinding these prohibited hunting practices.

Public comment on the Proposed Rule should be informed by this environmental analysis, and the comment period on the Proposed Rule should be extended to encompass release of the NEPA compliance document. NPS has already received extensive public comments, but commenters have not had the benefit of the NEPA analysis to comment on rules that are all about impacts on the environment. At present, the Proposed Rule includes no scientific basis to support a movement away from statutory mandate and departmental policy to reverse federal findings determined via extensive administrative review. NPS provides no scientific evidence to overcome or supplant its mandate to promote conservation interests over recreation interests, and NPS provides no scientific evidence supporting that the proposed action serves conservation interests, or any interests apart from those recreational interests identified in Secretarial Orders 3347 and 3356.

As discussed above, an EIS is required in light of the significant potential environmental impacts as well as controversial nature of the Proposed Rule. Even if NPS only issues an Environmental Assessment, however, NPS should provide a comment period on that document to be followed by a separate comment period on the Finding of No Significant Impact (FONSI), should NPS conclude that one is appropriate.

In closing, the Proposed Rule is highly controversial and has drawn national attention and interest. The Coalition appreciates NPS’s previous extension of the comment period on the Proposed Rule and encourages continued effort to accept and evaluate public input. However, we are gravely concerned that the Proposed Rule is simply unwarranted; it is poorly justified and in conflict with applicable federal mandates. Considering the harm that could be done to the ecosystems in our Alaska national preserves, it is imperative that the NPS carefully examine the potential environmental impacts of the Proposed Rule before rendering a final decision on whether to adopt the rule.